When the Terminals Went Dark: EO 14404 and Cuba's Card Networks
Visa and Mastercard went offline across Cuba on June 6. For compliance teams, the outage is less a travel inconvenience than the first visible fracture of a new secondary-sanctions regime — and a preview of what still sits in correspondent-banking exposure books.
On June 2, an unnamed foreign bank notified Cuba's Central Bank that it would terminate its relationship with Fincimex S.A. — the financial arm of GAESA, the military conglomerate that processes most international card traffic on the island. Four days later, Visa and Mastercard terminals went dark nationwide. Cuba Journal reported the human cost in The Only Cards Left: hotel checkout counters now display laminated lists of what still works — cash, Cuban prepaid cards, UnionPay, Mir.
This brief is for the compliance officer, fund counsel, and hospitality operator who needs the regulatory map behind that laminated card. Executive Order 14404, signed May 1, 2026, did not merely extend the Cuban Assets Control Regulations. It created a parallel IEEPA sanctions program with secondary exposure for foreign financial institutions that conduct or facilitate significant transactions involving persons blocked under the order — a structure previously associated with Iran and North Korea, not Cuba.
The June 5 wind-down deadline for GAESA-linked activity has passed. What follows is a subscriber-only walkthrough of the timeline, the Fincimex routing chain, FFI adjacency tests, and the payment rails that remain open — including why UnionPay and Mir routing creates a different compliance profile than the Western card networks that just exited.